2025 (5) TMI 713

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....led seeking quashing of notice dated 15.03.2018 issued under Section 148 of the Income Tax Act, 1961 (hereafter 'the Act') and order dated 11.12.2018 rejecting the objections filed by the petitioner. 2. The brief facts are that for assessment year 2011-12 the petitioner filed a return declaring 'Nil' income and showing the loss of Rs.4,10,457/-. As per the profit and loss account the net profit was Rs.1,64,51,540/- but while computing the book profit the net profit was reduced. The assessment was finalized on 14.02.2014 under Section 143(3) of the Act. On 15.03.2018 notice under Section 148 of the Act was issued. The reasons were supplied. The objections filed by petitioner were rejected, hence, the present writ petition. 3. Learned c....

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....on has been made for the relevant assessment year, no action shall be taken under this section after the expiry of four years from the end of the relevant assessment year, unless any income chargeable to tax has escaped assessment for such assessment year by reason of the failure on the part of the assessee to make a return under section 139 or in response to a notice issued under sub-section(1) of section 142 or section 148 or to disclose fully and truly all material facts necessary for his assessment, for that assessment year: Provided further that nothing contained in the first proviso shall apply in a case where any income in relation to any asset (including financial interest in any entity) located outside India, chargeable to....